AIA/CRS – Automatic Exchange of Information / Common Reporting Standard

The Automatic Exchange of Information (AEOI) based on the Common Reporting Standard (CRS) is a global OECD standard governing the systematic and periodic exchange of financial information between tax authorities across different countries. It was developed to combat cross-border tax evasion by requiring financial institutions to collect account data of foreign customers and report it to the competent national tax authorities, which then automatically transmit this information to the tax authorities of the respective countries of residence.

The CRS is considered the most significant multilateral instrument for promoting tax transparency since the introduction of the American FATCA regime and has fundamentally transformed the global tax landscape.

The foundations of the automatic exchange of information were laid by the G20 Declaration of 2013, in which heads of state and government mandated the OECD to develop a global standard. The OECD published the CRS in February 2014 and the associated Multilateral Competent Authority Agreement (MCAA) in October 2014.

• 2014: Adoption of the CRS by the OECD; signing of the MCAA by initial states
• 2016: First wave of 49 'Early Adopter' countries begins data collection
• 2017: First exchange of financial data between Early Adopters (September 2017)
• 2018: Second wave of additional jurisdictions begins data exchange; Switzerland begins its first data exchange with partner states
• 2019 onwards: Continuous expansion; today more than 120 jurisdictions participate in the CRS
• August 2022: OECD adopts CRS 2.0 ('Amended CRS'): expansion of scope to electronic money products, central bank digital currencies (CBDCs), and indirect crypto-asset investments
• June 2023: Finalization of the Amended CRS; consolidated version of the CRS framework published
• April 2025: Consolidated version of the CRS incorporating all Amended CRS changes published
• 1 January 2026: Amended CRS enters into force; first reporting obligations under the expanded framework expected from 2027

The CRS covers a broad range of financial institutions and financial accounts:

• Reporting institutions: Custodial institutions, depository institutions, investment entities, specified insurance companies
• Reportable accounts: Personal accounts and entity accounts of foreign tax-resident persons
• Reported information: Account holder identity (name, address, tax identification number), account balance/value, investment income (interest, dividends, other income) and gross proceeds from disposals
• Exceptions: Certain low-risk accounts such as government accounts, pension accounts and regulated collective investment vehicles may be excluded

The due diligence procedures for identifying reportable accounts differ depending on account type (new vs. pre-existing accounts) and account value (high-value vs. lower-value accounts).

Expanded scope under the Amended CRS (from 1 January 2026): The revised CRS 2.0 extends the scope to new classes of financial products:

• Electronic money products (e-money): Prepaid cards and other electronic payment instruments with a storage function
• Central bank digital currencies (CBDCs): Digital currencies issued by central banks
• Indirect crypto-asset investments: Investment vehicles investing in crypto-assets (e.g. crypto ETFs, certificates); direct crypto-assets are separately covered under the CARF framework

• Due Diligence: Financial institutions must determine the tax residence of all account holders and obtain corresponding self-certification forms
• Reporting obligations: Annual reporting of relevant account information to the national tax authority by a defined deadline
• Registration requirement: Financial institutions may be required to register with the competent tax authority in some jurisdictions
• Data protection and confidentiality: Exchanged information is subject to strict confidentiality rules and may only be used for tax purposes
• Sanctions: Non-reporting or incomplete reporting can lead to substantial fines and regulatory measures
• Group approach: Financial groups must ensure that all reportable group entities are integrated into the CRS process

1 correction:
- Predecessors array is empty despite FATCA being explicitly referenced as predecessor
2 updates:
- last_amended date (2023-01-01) is imprecise and outdated
- CRS 2.0 / Amended CRS completely missing from history, scope, and key requirements